Written evidence submitted by Fidra

The Environmental Audit Committee’s inquiry on coffee cups and plastic bottles highlights composting and recycling of paper cups is uncommon due to the waterproof polyethylene layer that is fused onto the paper cup. The evidence provided in this response identifies compostable packaging as a solution, provided the correct incentives and structures are put in place to develop this waste-stream.

Information relating to the other aspects of the Committee’s inquiry can be found in the evidence submitted by ‘Have You Got the Bottle’ campaign.

Executive summary

• Littering is an issue related to takeaway food packaging in both urban and non-urban areas, with a 59% increase recorded in fast food litter in England between 2004 to 2015.
• Where packaging is made from materials that can be recycled, food contamination can result in it being rejected from the recycling stream.
• Paper and card packaging can be problematic to recycle if made of a mixture of different materials, for example coated with plastic, and are poorly regulated as a food contact material with the potential to cause significant health risks. Such materials are destined for landfill, or incineration.
• A viable alternative is compostable packaging, made from a wide variety of raw materials which are often waste products, such as corn-starch. Being manufactured from plants, they are a natural and renewable resource with a significantly lower carbon footprint than oil-based plastics.  They offer a potential key to zero waste, as certified compostable products can be recycled with food waste, removing the limitations imposed by contamination.  In addition, businesses that use compostable packaging could save costs through reduction of their general waste stream.
• Logistical challenges to collecting food waste and compostable packaging exist through the nature of the fast food industry, where the product is taken away from the premises, requiring on-the-go recycling facilities.
• At present in the UK, only the Scottish Government has specific regulations requiring separate food waste collection, with exemptions for businesses in rural postcodes.  With limited regulatory incentive to have food waste collected, the ability to collect compostable packaging is restricted. 
• Where food waste is collected, the bulk is processed at Anaerobic Digestion (AD) plants. The initial treatment steps at AD plants are mechanical and remove most if not all packaging, making it an unsuitable route for effectively processing compostable packaging.  Commercial In-Vessel Composting (IVC) sites are limited and gate fees are higher than those for AD plants, offering no financial incentive.

1.       Who are we?

Fidra is a charity based in East Lothian, Scotland. We seek to find ways to engage local concerns over current and emerging environmental issues, and use this to contribute to wider dialogue at national and international levels. We use scientific evidence and best practice to establish how best to influence positive environmental change.

With fast food takeaways particularly prevalent in coastal tourist areas, an initial case study by Fidra centred on North Berwick highlighted many of the barriers to substituting current packaging with a compostable alternative.  However, it also highlighted possible solutions through the identification of the key issues. The challenges and solutions are presented here.

2.       What is the impact of disposable coffee cups and other fast-food packaging?

Many towns and cities encounter issues relating to takeaway packaging, including littering and limited opportunities for recycling. There has been substantial growth in the number of takeaway food outlets in recent years in the UK: a survey of 205 electoral wards in Norfolk with a total population of 796,728 showed a 45% increase in the number of fast food outlets from 1990 to 2008[1]. A subsequent England-wide study found a 59% increase in fast food-related litter for the period of 2004 to 2015, indicating correlation with increases in food and drink outlets[2].

It is estimated that 2.5 billion disposable coffee cups are used in the UK every year, with most ending up in landfill[3].  Disposable coffee cups tend to be plastics, including polystyrene, and paper or card, lined with plastic.  Where recycling opportunities exist, all these types of packaging present challenges in being recycled, either due to their structure or due to being contaminated with food or drink.

Using a compostable alternative could eliminate and reduce these concerns for disposable coffee cups and other forms of takeaway packaging. The idea of a ‘compostable town’ is evident in the USA where at least two cities, Richmond, CA and Oakland, CA, have stipulated the use of compostable packaging[4].

3.       Current policies and legislation

10 million tonnes of packaging waste are produced every year in the UK.  Of this almost two thirds are estimated to be recoverable, leaving a significant amount to go to landfill. Packaging waste is regulated by two sets of regulations under the EC Directive on Packaging and Packaging Waste [5] (Figure 1). These extend the principle of “the polluter pays”, ensuring the businesses who produce potential waste take responsibility for it at the end of its life.

These packaging regulations leave little responsibility to small and medium businesses in how their packaging is dealt with after use. The EU Waste Framework Directive[6] sets out five steps for dealing with waste, ranked by environmental impact.  It gives top priority to preventing waste, and when waste is created, priority goes to preparing it for re-use, then recycling, then recovery and last of all disposal (e.g. landfill).

Targets set by Scotland’s Zero Waste Plan[7] require 70% of all waste to be recycled and no more than 5% to be sent to landfill by 2025, with a ban on landfilling biodegradable waste from the end of 2020.

4.       Disposing of coffee cups

Consumer behaviour change

The lowest environmental impact to remove packaging from landfill would be to substitute it with reusable containers brought by the consumer, or provide returnable containers.  Both would require a significant behavioural change, and in the latter case would require resources to clean and store containers. Although many takeaway drink providers now encourage consumers to bring their own containers, the drinks are still often prepared in a disposable cup and then decanted.  This offers less risk of the cup reaching the environment as litter but puts it into the general waste stream, to landfill or incineration.  Vendors should be encouraged to make drinks in reusable, washable containers instead of in disposable ones.

Recycling coffee cups

Re-use and recycling of some makes of coffee cup are both possible.  However, at present these are small and localised, requiring a closed loop collection system[8].

Incineration of coffee cups

Incineration is widely used in Europe to recover the calorific value of waste that is not otherwise recycled.  There have been issues with emissions, capacities and costs of Energy from Waste facilities, with some proposed projects discontinued for financial or planning reasons[9]. A recent EU communication on Waste-to-Energy notes that circular economy proposals to increase waste recycling would result in a fall in feedstock for incinerators, with the result that public financial support for the recovery of energy from mixed waste may be phased out[10]. This indicates that incineration of waste is not a viable long-term solution.

Landfill

The disposal of materials in landfill is undesirable, largely due to the risk of leachate, and lack of breakdown of waste.  The Zero Waste Plan’s target is to reduce the proportion of waste reaching landfill to 5%.

5.       A solution: compostable packaging

Fast food and drink packaging is available in a range of materials such as plastics, paper or cardboard.  However, food contamination can cause problems with the recycling of all these materials, especially if containers are used for consumption away from households and therefore away from cleaning facilities.  Paper and card packaging is often tricky to recycle due to being made of a mixture of different materials, for example coated with plastic.  In addition, paper and card food contact materials are currently poorly regulated and may pose significant health risks[11]. As such materials are destined for landfill, or at best incineration. 

Compostable packaging has the potential to be a viable alternative, and can be made from a wide range of raw materials, which are often waste materials, such as corn-starch[12].[13]

So-called ‘bioplastics’ can be rated as degradable, biodegradable or compostable.  International Standards for measuring how plastics break down have been established[15] [16]. Figure 2 sets out the, sometimes confusing, terminology associated with the breakdown of this range of plastic materials.

Figure 2: defining degradable, biodegradable and compostable

6.       Use and collection of compostable packaging with food waste

The Waste (Scotland) Regulations 2012 require that from the end of 2016 all businesses and organisations producing over 5kg for food waste per week and in an urban area must present it for separate collection[17]. At present this does not apply to those with a rural postcode[18]. Eventually the regulations will bring into effect a ban on biodegradable waste being sent to landfill from 2020. It is unclear whether exemption under a rural postcode will still apply. There are no such requirements for businesses based in England, Wales or Northern Ireland, with voluntary objectives deemed sufficient.  All four Governments presently hold a voluntary agreement with food retailers and manufacturers called the Courtauld Commitment[19]. 

A Food Waste in England inquiry by the EFRA (Environment, Food and Rural Affairs) Committee was concluded in April 2017 and a report published[20].  One of the conclusions was that WRAP (Waste and Resources Action Programme) and Government should increase efforts to encourage participation in the Courtauld process.  In addition, a national food waste target was recommended to ensure a continued focus on reducing food waste.  Another recommendation was that Government requires food businesses and retailers to separate food waste.  The uptake of both recommendations would be an important opportunity to develop a suitable infrastructure in England for collecting compostable packaging with food waste.

Based on feedback received by Fidra from local businesses, in-house collection of compostable packaging for food and drink outlets is likely to take place separately to food waste. This would be most effective in the front-of-house accessed by customers, rather than in the service area.  Although the regulations use weight as a marker, waste collection vessels and charges are based on volume.  For example, businesses are charged for the volume of wheeled bin and the frequency with which it is emptied, irrespective of weight. Food waste collection units are small due to the heavy weight, which contrasts with compostable packaging which is light and therefore will require large volumes.  Combining food waste with compostable packaging would enable larger bins to be used, with the same frequency and similar charges.  Removing fast food packaging from the general waste stream would then require lower volume general waste bins.  In addition, the removal of food from the general waste could enable less frequent collections, as there would be no issues with organic waste decomposition.

By the nature of the product, fast food businesses have most of their packaging removed from the premises and as such are unable to control how it is recycled. Working alongside Councils to recover compostable packaging removed from premises could be coordinated with ‘on the go’ collection of both compostable packaging and food waste. In addition, street bins for compostable packaging could benefit from smart solar bins, which compact rubbish and inform when they are full[21].

7.       Processing of compostable packaging with food waste

High quality recycling of food waste is defined in the Scottish Government’s statutory Guidance on applying the waste hierarchy[22], as:

• Anaerobic digestion (AD) of source segregated food waste with energy recovery and production of PAS110[23] compliant outputs.
• In-vessel composting (IVC) of source segregated food waste where PAS100[24] standards are met.

Food waste and compostable packaging both constitute organic material that can be used as feedstock for anaerobic digestion and composting.  To be recovered by either process, packaging must conform to the European Standard EN 13432.

Not all materials are suitable for application to agricultural land meaning AD and composting cannot process all packaging materials. Some ‘biodegradable’ materials for example would not be suitable. SEPA’s Regulatory Position Statements on the Regulation of Outputs from Composting and Anaerobic Digestion Processes provide the exemptions and limits for physical contaminants [25] [26] [27] .

Scotland’s Circular Economy Strategy indicates that Scotland could become a leader in AD in parallel with the drive to reduce food waste[28]. Recent figures in Scotland show 51 operational AD plants, of which 8 are classed as municipal/commercial, and 29 active composting sites[29].  On a UK scale there are 578 operational AD plants of which 100 are classed as municipal/commercial, and 169 composting sites.

Furthermore, there is concern that the use of chemical fertilisers can have negative effects on the environment. The growing movement to develop new agricultural practices without environmental costs could incorporate the use of organic fertilisers made from secondary raw materials such as food waste or compost[30].  These are expected to become more important, as the reserves of non-renewable materials such as rock phosphate may become scarce[31].

Screening for contaminants takes place in both AD and composting. In composting, it is a manual process and relatively selective, with the result that compostable packaging can be retained if easily identifiable, i.e. by labelling or branding.  In AD the initial treatment process involves automated de-packaging, with most packaging removed. As this is automated there is no facility to distinguish between different types of packaging. East Lothian Council recently changed from using compostable bags for domestic food waste to plastic bags to enable easier removal in AD plants.  The physical properties of compostable bags resulted in stretching during the initial treatment of food waste, rather than shredding. Once stretched, they often became caught in machinery, requiring manual removal.  The plastic bags used as replacements disintegrate more readily, can be easily removed with other packaging and are suitable for energy recovery from incineration.

This suggests that currently only composting is a suitable route for food waste containing compostable packaging. 

8.       Recommendations

There is potential for significant steps to be made to both reduce the impacts associated with packaging materials which are not recyclable and don’t fully breakdown and improve the current infrastructure to create a truly circular economy for food and drink packaging.

The following recommendations are intended to contribute to the existing discussions taking place on packaging and the circular economy.

1. Expanded disposable coffee-cup levy: The Directive on packaging and packaging waste was amended to reduce the use of plastic bags by way of taxes or otherwise. It could also be amended for disposable coffee-cups, with charges being implemented in a variety of ways. For example: incentivising use of alternative materials through a levy with the vendor retaining enough to cover additional costs if using e.g. compostable packaging, and for those using non-compostable packaging all levy goes back to government, or an environmental levy is imposed on the vendor which cannot be passed on to customers[32].

3 Facilitating compostable packaging collection with food waste: implementing a ‘Food on the Go’ type scheme where vendors have waste bins outside their premises and sponsor waste bins at strategic points which can be collected and fed into local food waste collection services.

4. Facilitate structural changes to food waste collection systems: Ensure compostable materials are fully processed with food waste; this may require incentivising the use of In-Vessel Composting processes as opposed to Anaerobic Digestion or Energy from Waste until compostable packaging can be handled by all food waste facilities. Incentives could include subsidising gate fees charged to waste companies, for example.

CASE STUDY 1: Could a town become fully ‘compostable’?

East Lothian Council (ELC) believe that returns from the waste haulage contractor used for municipal waste collections demonstrate a distinct pattern for North Berwick.  There is a significant difference in the tonnage per m3 of mixed waste between North Berwick and ELC’s other 5 operational centres (Table 1). 

Table 1: Volume of mixed waste per tonne for East Lothian Council's operational centres[33]

The cubic meter figure is based on number and cubic capacity of skips and suggests that twice as much bulk is collected from North Berwick as from the 5 other clusters.  The only explanation ELC have for the anomaly is the high volume of polystyrene collected from street litterbins.  With a large number of businesses providing takeaway food and drink, and a busy tourist season, a polystyrene ban would be unfeasible without the use of alternative materials.   

ELC have expressed interest in using cardboard as an alternative food and drink packaging, due to its ability to be compacted more readily than EPS, recycled if not heavily contaminated and biodegraded if in the environment or landfill.  However, there is little cardboard packaging that is certified for use as a food contact material if it is not lined with plastic, which then affects its ability to be recycled or biodegrade.  Compostable packaging appears to offer a solution to this, as being plastic-free it could be collected and processed with food waste.  However, due to commercial and domestic food waste collection in East Lothian being presently processed through ADs, compostable packaging will be diverted to landfill or incineration.  If a system could be established to successfully collect compostable packaging and food waste together, and then process them to produce compost, North Berwick could become a compostable town’ in terms of fast food and drink packaging.  This could be used as a promotional aspect of the town as a tourist destination. 

It is understood that many of the take away businesses in North Berwick will have the packaging removed from the premises and as such won’t be able to control the recycling of that packaging. Working alongside East Lothian council, perhaps with some funding from Zero Waste Scotland, to implement ‘on-the-go’ recycling for compostable packaging and food waste should be considered.  Areas where concentration is high (at the beach front, outside chip shop etc.) could be a focal point. This could provide a case study from which other communities could replicate and learn from.  Such a project would involve the following stages: 

1. Identifying key stakeholders, agreeing project aims and objectives;  
2. Getting businesses on board, and making the switch;  
3. Communicating to the community; 
4. Implementing recycling ‘on the go’.  

Keenan’s Recycling, a Scottish organic waste collector based in Aberdeen and currently covering food waste collections in North Berwick, would like to see efficient processing of compostable packaging with food waste.  They have expressed interest in being involved in exploring effective collection systems, including branding of packaging and collection points.  At present, they can only take compostable materials to their IVCs in Aberdeen, which is unfeasible for Southern Scotland.  Gate fees at Levenseat, the nearest alternative to East Lothian, are prohibitively high. Keenan's have a site in development at Linwood, Paisley near Glasgow, with which they intend to service Southern Scotland.  A trial was run in Glasgow in early 2017 in association with compostable packaging supplier Vegware, with collections being taken to GP Plantscapes in Lanark.  The trial found high levels of contamination in the collections, with all collections rejected by the receiving site.

Vegware has subsequently registered as a waste broker and ran a recent trial of the collection of its products with food waste from its own offices and selected businesses in Edinburgh and Glasgow.  The trial was deemed successful and has led to permanent waste collection streams collecting compostable packaging with food waste.  The nominated collector used for the trial collects dry recycling from a large supermarket chain but has space to collect food waste and is licensed to do so.  Collections are taken to GP-Green based in Blantyre.  There is potential to expand this route and collections, however there is no incentive for businesses to take part in areas designated to have a rural postcode and therefore exempt from the change in legislation in 2016 requiring businesses with over 5kg of food waste to have separate collections.

A review of suitable suppliers of compostable packaging would be required.  Vegware is already used locally, and as a company can support businesses in sourcing suitable compostable alternatives to current products and advise on a suitable distributer to purchase through. A possibility would be to partner with one of Vegware’s existing distributers in order to reduce the impact of deliveries with all businesses sourcing from one supplier – adding more environmental benefits to the project.   Vegware’s initiative The Food Waste Network can advise businesses on establishing a food waste collection route for used packaging and food waste. Ideally, businesses in close proximity could all be serviced by one collector, creating a carbon friendly collection route.  

Businesses in Scotland can benefit from consultation support offered by Resource Efficient Scotland, to cut costs and increase resource efficiency. Funded by Zero Waste Scotland, it can help with implementing changes in small to medium sized businesses (SMEs) by offering up to 5 days consultation free of charge, provides help with grant applications and has 0% interest loans available to implement changes.   

North Berwick businesses are currently exempt from the food waste regulations, independent of their size or the amount of food waste produced, due to the rural postcodes classification used by the Scottish Government. However, collections are becoming more widely available throughout these areas, for example with Keenan’s recycling operating in North Berwick. Getting food businesses recycling their food and compostable packaging on a town wide scale might encourage the government to reconsider the rural / non-rural classification.

CASE STUDY 2: Whynot café, North Berwick

A not-for-profit community café in North Berwick has initiated its own recycling system for its takeaway food and drink packaging.  Its owners implemented the scheme having witnessed the high levels of litter in North Berwick street bins.  They consulted with their waste collector, Max Recycling, on types of takeaway food packaging that it could recycle. Suitable packaging was then sourced, at a greater cost to that being used previously.

The scheme asks customers to return the café’s takeaway food and drink packaging to the café, which will take it back and add it to its own dry recycling bin.  The customer receives a 10% discount to be used in the café or the associated delicatessen.  To cover costs of the discount and the more expensive packaging, the café has instigated a 5p increase on its coffee prices.  According to the owners this has not been commented on by customers. 

The scheme was started in July 2017[34].  Despite little take up in the first month, the owners plan to keep the scheme in existence.  The café does not have food waste collected due to the current exemption and has not found contamination of returned packaging with food to be an issue. 

Although on a small scale and with a limited take up, this case study demonstrates that such a scheme is relatively simple to implement and can effect behavioural changes in customers.  Zero Waste Scotland and Resource Efficient Scotland both have potential roles in encouraging similar schemes within other SMEs.

September 2017

2